Biometric Data Retention and Destruction Policy

Effective Date: August 19, 2026

1. Purpose

This policy describes how DateGuard collects, uses, stores, and destroys biometric data in compliance with applicable laws including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and Washington State's biometric privacy law (HB 1493).

2. Definitions

"Biometric Identifier" means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry.

"Biometric Information" means any information, regardless of how it is captured, converted, stored, or shared, based on a biometric identifier used to identify an individual.

3. Types of Biometric Data Collected

• Facial Geometry Scan — captured during liveness verification via Facia.ai
• Vocal Biomarkers — captured during Vocal Bio sessions via Emotion Logic (for Safety + Vocal Bio tier users)

4. Purpose of Collection

• Facial scan: To verify the user is a real, live person (anti-spoofing)
• Vocal biomarkers: To analyze emotional authenticity indicators during dating conversations

5. Consent

We obtain written, informed consent before collecting any biometric data. Users are informed of the specific data collected, the purpose of collection, and the applicable retention schedule. Users must affirmatively opt in via an explicit consent checkbox before any biometric data is captured or processed.

6. Disclosure

We do not sell, lease, trade, or otherwise profit from biometric data. We disclose biometric data only to the following service providers, each of which is contractually bound to comply with applicable biometric privacy laws:

• Facia.ai (facial liveness processing)
• Emotion Logic (vocal biomarker analysis)

7. Retention Schedule

• Raw facial images: Deleted immediately upon completion of the liveness check (not stored by DateGuard; Facia.ai processes and discards the image)
• Liveness verification result: Pass/fail status and timestamp are retained for the duration of the user's account
• Vocal biomarker scores: Retained for the duration of the user's account or 3 years from the date of last interaction, whichever is sooner
• Upon account deletion: All biometric-related data is permanently destroyed within 30 days

8. Destruction

When biometric data reaches the end of its applicable retention period, or upon a valid user request, it is permanently and irreversibly destroyed using industry-standard data sanitization methods.

9. Data Security

Biometric data is protected using encryption in transit (TLS 1.2+) and at rest. Access is limited to authorized personnel and automated systems on a strict need-to-know basis.

10. User Rights

Users may:

• Request disclosure of the biometric data DateGuard holds about them
• Request deletion of their biometric data
• Withdraw consent at any time (the associated feature becomes unavailable if consent is withdrawn)
• File complaints regarding DateGuard's collection or handling of biometric data

To exercise any of these rights, contact [email protected].

11. Updates

We may update this policy from time to time. Material changes will be communicated to users via email or in-app notification.